Home Case Index All Cases Income Tax Income Tax + AT Income Tax - 2023 (4) TMI AT This
Forgot password New User/ Regiser ⇒ Register to get Live Demo
2023 (4) TMI 455 - AT - Income TaxTP Adjustment - ALP adjustment of international transactions with overseas Associated Enterprises pertaining to manufacturing segment - internal rejection of assessee’s comparables - HELD THAT:- We make it clear that we are dealing with the assessee’s Transactional Net Margin Method [ “TNMM”] having profit level indicator than exact product similarly as held in Gemstone Glass (P.) Ltd. [2015 (11) TMI 185 - ITAT AHMEDABAD]. Faced with the situation, we adopt judicial consistency qua the instant sole surviving issue and leave it open for the learned Transfer Pricing Officer [in short “TPO”] to compute the assessee’s ALP in light of its internal comparables as per law in very terms.
|